Is Windows Recall Safe? Screenshots of Client Data

It depends: Windows Recall encrypts snapshots locally, but it can create unplanned copies of client screens. Keep it off unless your practice approves that copying.

Include Recall in your AI privacy rules when issuing new laptops. Approval to open a client portal does not automatically approve keeping screenshots of it.

Is Windows Recall Safe for Client Work?

Windows Recall saves encrypted screen snapshots on the laptop. Windows Hello protects access. Microsoft’s Recall privacy guidance says Recall does not automatically share snapshots with Microsoft or other users.

Those protections address access to saved copies. Your practice still needs a reason to create the copies and a decision about how long to keep them.

Recall requires the user to opt in. Microsoft also disables and removes it by default on commercially managed devices. A new laptop offering Recall is therefore different from one already saving snapshots.

Consider a hypothetical client portal session. A staff member views confidential correspondence, then signs out. If Recall saved the screen, signing out of the portal does not remove that separate local copy.

What Recall Captures

Windows 11 Recall runs on compatible Copilot+ PCs. Microsoft’s device requirements include device encryption and Windows Hello enrolment with a biometric sign-in option.

After opt-in, Recall saves snapshots every few seconds and when the active window changes. It analyses them locally so the user can search visible text and images. It does not record continuous video or audio.

Retention depends on the configured duration and storage allowance. Microsoft’s managed-device guidance permits duration limits of 30, 60, 90 or 180 days on Enterprise and Education editions.

Without a configured managed-device duration limit, snapshots remain until the storage allowance is reached. The oldest are then deleted first. Read the laptop’s actual settings before treating snapshots as short-lived records.

Sensitive information filtering is on by default. Microsoft’s filter reference includes Australian Tax File Numbers and bank-account numbers among the types it detects.

The filter recognises types of information. It does not decide whether your practice has permission to retain a client’s correspondence. Advice about a family dispute can be confidential without containing a recognised identifier.

Website exclusions also have limits. Microsoft says parts of excluded sites can appear through embedded content or browser history. Excluding a portal address therefore does not establish that every view of its content is blocked.

Turning Off Windows Recall

Turn off snapshot saving on each laptop, or use managed-device policies to prevent staff enabling it. A temporary pause leaves Recall available to resume.

On One Laptop

Follow Microsoft’s Recall settings instructions while signed in as the relevant user:

1. Open Settings, then Privacy & security, then Recall & snapshots.
2. Set Save snapshots to Off. Complete the Windows Hello check if prompted.
3. Reopen the settings page and confirm Save snapshots remains off.
4. Review existing snapshots separately. Switching saving off does not establish that earlier copies have been deleted.

The Recall saving icon disappears from the system tray when Save snapshots is off. If the settings page is absent, have your administrator establish the device’s eligibility and applied policy before recording its status.

If existing snapshots are no longer required, use the deletion options in Recall & snapshots under your practice’s retention procedure. Preserve material needed for an investigation or legal requirement before deleting anything.

Across Managed Devices

Your administrator can use Microsoft’s Windows AI policy reference on supported Windows 11 Pro, Enterprise and Education devices.

1. Assign the policy to every eligible practice device through your device-management service or domain policy.
2. Under Computer Configuration, Administrative Templates, Windows Components, Windows AI, set Allow Recall to be enabled to Disabled. Its policy identifier is AllowRecallEnablement.
3. To prohibit snapshot saving, enable Turn off saving snapshots for use with Recall. Its identifier is DisableAIDataAnalysis, with a value of 1.
4. Apply the policy and restart devices where required. Confirm successful deployment in management reports and inspect the resulting setting on a representative laptop.

Disabling Recall’s availability removes its component and requires a restart. Both disabling availability and enabling the snapshot-saving prohibition delete existing snapshots. Resolve any preservation requirement before deploying these policies.

The policy names point in opposite directions: disable permission to enable Recall, but enable the prohibition on saving. For wider account settings, use the Microsoft 365 security guide.

Recall and Your Record-Keeping Duties

Unplanned snapshots add another place where client information exists. Your practice must account for that copy when deciding who can access information and when to remove it.

For practices covered by the Privacy Act, Australian Privacy Principle 11 requires reasonable steps to secure personal information. It also requires destruction or de-identification when information is no longer needed, subject to record-retention exceptions.

A portal’s retention arrangements do not remove your responsibility for a screenshot held on your laptop. Include Recall in the device inventory and in any assessment of information exposed after a device incident.

The Notifiable Data Breaches scheme requires covered entities to notify eligible breaches likely to cause serious harm. Saving a snapshot alone does not establish a notifiable breach. Assess actual access and the likely consequences.

Record whether snapshot saving is permitted in your practice cyber security rules. Make that decision part of laptop setup, before staff view client files.